purchasing them) which they are then expected to offset correctly without regulation do not require organizations to investigate correlations of all internal risks they own do not tax or charge institutions for the systematic or aggressive externalization or conflicted marketing of risk—other than requiring an orderly unravelling of derivatives in a crisis and stricter record keeping Since derivatives present major unknowns in a crisis these are seen as major failings by some critics causing several to claim that the "too big to fail" status remains with respect to major derivatives dealers who aggressively took on risk of an event they did not believe would happen—but did. As Basel III does not absolutely require extreme scenarios that management flatly rejects to be included in stress testing this remains a vulnerability. A few critics argue that capitalization regulation is inherently fruitless due to these and similar problems and—despite an opposite ideological view of regulation—agree that "too big to fail" persists. Basel III has been criticized similarly for its paper burden and risk inhibition by banks, organized in the Institute of International Finance, an international association of global banks based in Washington, D.C., who argue that it would "hurt" both their business and overall economic growth. Basel III was also criticized as negatively affecting the stability of the financial system by increasing incentives of banks to game the regulatory framework. The American Bankers Association, community banks organized in the Independent Community Bankers of America, and others voiced opposition to Basel III in their comments to the Federal Deposit Insurance Corporation, saying that the Basel III proposals, if implemented, would hurt small banks by increasing "their capital holdings dramatically on mortgage and small business loans". Former US Secretary of Labor and Professor of Economics at the University of California, Berkeley Robert Reich has argued that Basel III did not go far enough to regulate banks since, he believed, inadequate regulation was a cause of the global financial crisis and remains an unresolved issue despite the severity of the impact of the Great Recession. In 2019, American investor Michael Burry criticized Basel III for what he characterizes as "more or less remov[ing] price discovery from the credit markets, meaning risk does not have an accurate pricing mechanism in interest rates anymore." Before the enactment of Basel III in 2011, the Institute of International Finance (IIF, a Washington, D.C.–based, 450-member banking trade association), argued against the